On October 1, 2020, the regulations requiring the submission of a Polish new standard audit file for tax called JPK_ VAT7M / VAT7K will enter into force, which will replace both the VAT declaration and the current JPK_VAT information. As a consequence, the obligation to submit a VAT declaration will be combined with the obligation to send JPK_VAT files.
It also means that from that date, taxpayers are obliged to provide additional data necessary to prepare JPK_ VAT7M / VAT7K.
As a rule, the purpose of the new SAF-T was to simplify VAT reporting. However, in practice, the introduction of JPK_V7M / JPK_V7K will involve a number of additional activities both on the part of accounting provider and the company. One of the key changes is the obligation of taxpayers to verify the goods sold and the services provided in terms of their belonging to one of the thirteen commodity and service groups and markings relating to certain transactions. This additional information is required for analytical purposes of tax authorities, including selecting entrepreneurs for inspection.
The scope of data that must be collected to complete the new JPK_ VAT7M / VAT7K correctly, e.g. marking the type of proof of sale, completing a code of goods and services, marking the procedure, etc. will therefore be wider. The requested data is related more to the nature of the business and the business model of the company, than the accounting and tax information, which so far was sufficient to prepare a tax declaration.
In connection with the above, the new reporting standard in the form of JPK_ VAT7M / VAT7K forces all companies to provide additional information, as follows:
- 1. GTU codes of goods and services sold, if the goods sold and services provided by the company are listed in §10 point 3 of the Ordinance of the Minister of Finance, Investments and Development of October 15, 2019 on the detailed scope of data contained in tax declarations and records in the scope tax on goods and services,
- 2. Procedures and types of transactions – described in §10 point 4 of the above-mentioned Regulations,
- 3. Proofs of sale – described in §10 item 5 above Regulations
Without this information, it will not be possible to prepare a correct JPK_ VAT7M / VAT7K.
The consequence of sending JPK_ VAT7M / VAT7K containing unreliable, e.g. incomplete or faulty data may be sanctions imposed on the taxpayer in accordance with the applicable regulations resulting from the KKS (Penal and Fiscal Code). It is worth noting that along with the provisions on the new structure, parallel provisions were introduced regarding the possibility of imposing sanctions for errors that make it impossible to verify the correctness of transactions, in the amount of PLN 500 for each error.
